Frontier Tower Service, Inc.

Environmental Health and Safety Program Manual

Programs for the Health, Safety and Well‐Being of Employees

FTSI 16

Revision 1.20.16

BH

1

Frontier Tower Service, Inc. 2015

[Type text]

15

Frontier Tower Service, Inc. 2015

Safety Goal14

General Commitment15

Management Commitment to Safety15

Management (will)15

Safety Director (will)15

Supervisors (will)16

Employees17

Accountability for Safety17

Opinion Survey17

Employee Suggestions17

Employee’s Safety Suggestion18

Standards19

Safe Operating Procedures19

Rules19

Housekeeping19

Disciplinary Program20

Job Hazard Analysis Program22

Job Safety Analysis22

Responsibilities22

Documents23

JSA Process23

Development of JSA23

Accident Management25

Accident & Near Miss Reporting Procedures25

Accident Investigation25

APPENDIX A: ACCIDENT/INCIDENT INVESTIGATION PHASES26

Phase 1: Identify and Collect Facts26

Phase 2: Determine Basic Causes26

Phase 3: Determine Root Causes27

Phase 4: Recommend Corrective Action27

Supervisor’s Accident Investigation Report28

Behavior Based Safety Program29

SCOPE:29

REQUIREMENTS:29

Observation and Feedback29

Data Management:30

CRITICAL BEHAVIOR INVENTORY DEFINITIONS32

BEHAVIOUR OBSERVATION SHEET37

Manual lifting Program39

Purpose39

Key Responsibilities39

FRONTIER TOWER SERVICE INC Safety Administrator39

Worksite Manager40

Employees40

Procedure40

Worksite Assessment40

Work Controls41

Handling Heavy or Awkward Loads41

Incidents and Injuries42

Review & Updating Lifting and Handling Loads Program42

Training42

1. Awkward Postures43

2. Static Whole Body Postures44

3a. Lift/Lower Forces (manual labor)45

3b. Lift/Lower Forces (office work)45

4a. Push/Pull Forces (manual labor)45

4b. Push/Pull Forces (office work)46

5. Repetition46

6. Hand/Arm Vibration46

7. Repeated Impacts47

1.How many employees are exposed to the hazards identified above and how often?48

2. In the past two years, how many MSD incidents been reported among employees who are exposed to the identified hazards? State the number of incidents and their nature (e.g., Lost Time, Medical Aid, First Aid, Incident only)48

Drug and Alcohol Policy49

Policy Statement51

Prohibitions52

Alcohol Prohibitions,52

Drug Prohibitions52

Conducting Tests53

Conducting Alcohol Tests53

Conducting Drug Tests53

Specimen Collection Protocol54

Required Testing55

Pre-employment Testing55

Reasonable Suspicion Testing55

Post Accident Testing56

Consequences of Positive Test Results58

Access to Facilities and Records58

Employee Education59

Referral, Evaluation and Treatment59

Access to Records59

Forms60

Policy Acknowledgment61

Drug & Alcohol Testing Notification,62

Employee Add or Delete Form63

Pre-employment Drug Test Consent64

Drug Test Results65

Request for Information66

Reasonable Suspicion Record67

ALCOHOL, DRUG AND CONTRABAND POLICY69

Purpose:69

Definitions:69

Personnel69

Prohibitions:69

Searches and Inspections70

Testing70

Categories70

Comparable-to-Designated:70

Safety-Sensitive:70

Low-Exposure:71

Requirements:71

Pre-Access Testing:71

Random Testing:71

Post-Incident Testing:71

Reasonable Suspicion Testing:72

Non-Compliance:72

Drug Awareness:73

Applicable Laws:73

Alcohol, Drug and Contraband Testing Information74

Respiratory Protective Equipment Program75

Scope75

Selection75

Medical Evaluation.75

Fit Testing75

Use of Respirators76

Maintenance and Care of Respirators76

All respirators are to be inspected as follows:76

Respirator inspection shall include the following:76

Training.77

Construction Site Crystalline Silica Exposure78

Safeguards for Reducing Exposure to Crystalline Silica78

Hydrogen Sulfide Hazard Awareness Program79

Purpose79

Scope79

Regulatory References79

Policy79

Responsibilities80

Management80

Supervision80

Employees81

Hazard Recognition & Control81

Where do you find Hydrogen Sulfide?82

Health Hazards Associated with Hydrogen Sulfide82

Long Term Health Effects of Exposure to Hydrogen Sulfide82

Controls & Protection82

Engineering Controls82

Safe Working Practices82

Protection83

Training83

Training Content83

Personnel Training83

Training Frequency84

Reporting and Recordkeeping84

Flame-Resistant Clothing Program86

OSHA86

NFPA 211286

Hearing Conservation / Noise Exposure Program92


 Electrical Safety Program93

QUALIFIED / NON QUALIFIED93

Defining “Qualified”93

TABLE 195

TABLE 296

Ground Fault Circuit Interrupters97

Lock Out / Tag Out Program98

Lockout/Tagout Procedure Checklist Energy Source Determination102

Confined Space Entry105

Purpose105

Definitions106

Confined Space:106

Permit Required:106

Hazards106

Procedures107

Rescue Equipment & Procedures108

Equipment108

Rescue Procedures108

Training109

FIRST AID PROGRAM110

Bloodborne Pathogen Exposure Control111

Exposure Control111

Control Methods111

Recordkeeping112

Bloodborne Pathogen Exposure Control Maintenance Record114

Bloodborne Pathogen Summary Log115

Hazard Communication Program1

Introduction1

Objective1

Scope1

Hazardous Chemicals1

Hazard Communication Program2

Chemical Inventory List2

Precautionary Labeling2

Containers in the Workplace2

Portable Containers4

Update and Review4

SAFETY DATA SHEETS (SDS)5

SDS Format5

Radio Frequency Safety Program20

Purpose and Requirements20

Scope and Regulations20

General Federal Regulations20

FCC Requirements20

OSHA Regulations20

IEEE/ANSI Standard2

ICNIRP Recommendations2

ACGIH TLVs2

All Limits and Guidelines Comparison2

Definitions2

Biological Effects3

Specific Thermal Effects4

Nonthermal Effects4

Other Effects4

RF and Microwave Exposure Limits5

Electric Shock Hazards5

Personal Protective Equipment (PPE) Program18

Hazard Assessment Form19

Training Documentation for Personal Protective Equipment20

Tool Safety Program21

Hand Tools22

Power Tool Precautions22

Powered Abrasive Wheel Tools24

Pneumatic Tools25

Powder-Actuated Tools25

Hydraulic Power Tools26

Hot Works Program27

Purpose:27

Responsibility:27

Scope:27

Definitions:27

Hot work27

Safe Work Areas27

Procedures:27

Not Permitted27

Fire watch:28

Hexavalent Chromium Program29

Introduction29

Effects Of Inhalation29

Effects Of Skin Exposures30

Medical Surveillance31

Protective Clothing & Equipment32

Responding To Exposures33

HEXAVALENT CHROMIUM EMPLOYEE TRAINING34

Fire Prevention Program36

Purpose36

Responsibilities36

Fire Emergency Procedures40

TRENCHING AND EXCAVATION41

Hazards42

Soil Classification.44

Sloping and Benching48

One- Call Procedure53

Before you dig more than 12 inches, call 811—it’s the law.53

TEMPORARY MARKING GUIDELINES54

GUIDELINES FOR UNIFORM TEMPORARY MARKING OF UNDERGROUND FACILITIES56

Competent Person Safety Training and Soil Testing Program57

OSHA Requirements for Excavations and Trenching57

Definitions of Excavation and Trenching57

Definition of Terms58

The Key To Protecting Yourself64

Preplanning64

Training68

Construction Equipment69

Hazardous Atmosphere71

Confined Spaces73

Overhead Loads74

Water Accumulation74

Adjacent Structures75

Protection from Loose Rock75

Inspectors76

Soil Classifications77

OVERVIEW: SOIL MECHANICS.77

BOILING78

UNIT WEIGHTOF SOILS79

Determination of Soil Type79

More on Soil Classifications80

Discussion of Four Categories of Soil80

To Type or Classify Soils82

Trench Protection Requirements88

Shoring Systems89

Sloping and Benching Systems89

PROTECTIVE SYSTEMS59

Shoring Types59

TRENCH SHIELDS63

Emergency Action Plan Program109

Heat and Cold Stress Program112

Introduction112

Responsibilities112

Heat Related Illnesses; Signs, Treatment and Prevention113

Cold Related Illnesses and Injuries; Signs, Treatment and Prevention115

Training117

Appendix A Heat Index118

Appendix B121

Asbestos Program122

General122

Asbestos Containing Materials122

Health Effects From Exposure To Asbestos123

Limiting Exposures123

Cranes and Rigging Program125

Crane Inspections.126

General Rigging Safety126

Rigging Inspections127

Mechanical Splice128

Forklift Safe Operations Program131

Operator Training131

Safe Forklift Operations131

Traveling132

Loading and Unloading133

Maintenance133

Fall Protection Program134

General134

Basic Requirements134

Personal Fall Arrest Systems134

Positioning Device Systems135

Anchorage Points136

Basic Climbing Techniches136

Fall Protection Equipment137

Equipment Inspections138

Equipment Care and Maintenance138

Full Body Harness138

Shock Absorbing Lanyards139

Calculation Fall Clearance139

Positioning Lanyards140

Anchorage Straps140

Snaphook and D‐Rings140

Careeners141

Self-Retracting Lifelines(SRLs)141

Lifelines and Rope Grabs141

Cable Grips and Safe Climbs142

Training142

Tower Rescue143

Fixed and Portable Ladders143

Guardrail Systems143

Glossary of Fall Protection Terms144

Scaffold Safety Program146

Purpose146

Applicability146

Reference146

Policy146

Responsibilities146

Procedure147

Definitions147

Training148

Safe Scaffold Erection and Use148

Types of Scaffolds148

Responsibilities149

Competent Person150

Safety Requirements for Scaffolds150

Aerial Lift Safety Program154

Overview154

Policy154

Requirements154

Purpose154

Scope155

Identification of Lift(s) in Use155

General Safe Work Practices155

Safe Work Practices Before Operation156

Safe Operation During Operation156

Safe Work Practices After Operation157

Changing and Charging Batteries157

Maintenance158

Responsibilities158

Supervisors158

Operators159

Occupational Health and Safety Coordinator159

Training Requirements159

Initial Training160

Annual Training – must include at least the following160

Training Records160

Program Evaluation161

Pre-Use Inspection Checklist for Aerial Lifts163

Frequent Inspection Checklist for Aerial Lifts164

Work Area Inspection Checklist for Aerial Lifts165

Stop Work Authority Program167

Purpose167

Scope167

Key Responsibilities167

Stop Work Authority Procedure167

Follow-Up167

Fleet Safety Policy168

General Vehicle Safety Rules178

CELL PHONE POLICY180

Subcontractor Policy189

Safety Goal

Employee and subcontractor safety and well being is the major concern at Frontier Tower Service, Inc. No project is important enough for us to perform the work in an unsafe and inefficient manner. Our company’s goal is to minimize injuries in the pursuit of eliminating accidents all together.

Frontier Tower Service, Inc. reaches this goal through research, audits and reviews. We reserve all of the company’s safety policies in order to protect the company’s employees and maintain compliance with government agencies. We also conducts scheduled and unscheduled site audits to ensure compliance in the field. In addition, we investigate all accidents and modify our policies and procedures to prevent reoccurrence.

Frontier Tower Service, Inc. facilitates in-house and outsourced training in all aspects of tower construction, mantainance and installation. We provide in-house certifications for Compatint and Rescue Climber, Qualified Oporater, first aid and CPR, as well as H2S, Stop Work Authority and all other oil field specific OSHA Compliance training.

Employee safety Training is conducted:

· At time of hire

· When regulations are updated

· When performing non-routine tasks

· After an accident or a near miss

· On a regular basis

To keep safety top priority for our newer employees, Frontier Tower Service, Inc. has implemented a tower climbing school. At this school the newly hired employee gains experience in climbing safety, inspecting the tower, gin pole and stacking procedures, riding the line and plumbing and tensioning. Authorized Climber, Competent Climber, and Competent Rescuer courses are also taught in-house.

Our Safety Program includes OSHA qualified "competent personnel" on site at all times. We also enforce our policies through disciplinary actions.

Through the use of our training, disciplinary tools and open door management, employees become familiar with the applicable standards and safe working procedures. Because safety begins with the individual, all employees are expected to actively contribute as Frontier Tower Service, Inc. accomplishes our safety go

General Commitment

Management Commitment to Safety

Management is concerned about employee safety. Accidents, unsafe working conditions, and unsafe acts jeopardize both employees and Company resources. Injuries and illnesses result in discomfort, inconvenience and possibly reduced income for the employee. Costs to the Company include direct expenses (workers’ compensation premiums, damaged equipment or materials, and medical care) and indirect expenses (loss of production, reduced efficiency, employee morale problems, etc.). These indirect costs are reported to cost 4-10 times more than the insured costs of an accident. Accordingly, Management will provide sufficient staffing, funds, time, and equipment so those employees can work safely and efficiently.

Assignment of Responsibilities

Safety is everyone’s responsibility. Everyone should have a safe attitude and practice safe behavior at all times. To best administer and monitor our safety policies, the following responsibilities are delegated. This list should not be construed as all-inclusive and is subject to change as needed.

Management (will)

Provide sufficient staffing, funds, time, and equipment so that employees can work safely and efficiently

Demand safe performance from each employee and express this demand periodically and whenever the opportunity presents itself.

Delegate the responsibility for a safe performance to the Safety Director, Supervisors, and Employees, as appropriate.

Hold every employee accountable for safety and evaluate performance accordingly.

Periodically review the Safety Program effectiveness and results.

Safety Director (will)

Provide the resources, direction, and audits to integrate safety into the management system.

Establish and maintain a safety education and training program.

Periodically conduct safety surveys, meetings, and inspections.

Advise supervisors, employees, and the safety committee on safety policies and procedures.

Assure that all newly hired employees have been given a thorough orientation concerning the Company’s Safety Program.

Coordinate with Human Resources pre-employment physicals and maintain the company’s drug-testing program.

Prepare and maintain safety records, analysis, evaluations, and reports to improve the Company’s safety performance and comply with all government agencies, insurance carriers, and internal procedures.

Work with management, supervisors, safety committees and employees to maintain & implement new and ongoing safety programs and comply with recommendations provided by outside consultants, OSHA inspectors, and insurance companies.

Make available all necessary personal protective equipment, job safety material, and first-aid equipment.

Review all accidents with management, supervisors, the safety committee and/or employees and ensure that corrective action is taken immediately.

File all workers’ compensation claims immediately and work with the workers’ compensation carrier to ensure proper medical treatment is provided to injured workers and they are returned to work as quickly as medically possible.

Supervisors (will)

Each employee, who is in charge of a specific work area, supervises the work of others, or to whom an employee is assigned for a specific task or project, is responsible and accountable for their safety. Supervisors will:

Establish and maintain safe-working conditions, practices, and processes through:

· Job Safety Analysis (see Return to Work section for sample)

· Job Inspections

· Safety Meetings

· Safety Training

Observe work activities to detect and correct unsafe actions.

Ensure that all injuries are reported promptly and cared for properly. Make available first aid treatment.

Investigate all accidents promptly. Complete an accident report and provide it to the Safety Director the same day the accident occurs. Review all accidents with the Safety Director and employees and correct the causes immediately.

Assist Human Resources in the review of employment applications, pre-employment physicals reports, and personnel files to determine physicals qualifications for specified job classifications.

Seek out alternative work so that injured employees can return to work in a modified duty job.

Consistently enforce safety rules/regulations, programs, and protective measures (i.e. use of personal protective equipment, machine guarding, proper clothing, etc.)

Post signs, notices, and instructions as needed or required.

Brief your employees of any new hazards before they start work and weekly host brief safety meetings to discuss safety practices related to job hazards and general safe work behavior.

Work with management, the Safety Director, safety committees and employees to maintain & implement new and ongoing safety programs and comply with recommendations provided by outside consultants, OSHA inspectors, and insurance companies

Employees

Each employee is responsible for his/her own safety. No task should be completed unless it can be completed safely. Employees will:

Comply with all company safety programs, rules, regulations, procedures, and instructions that are applicable to his/her own actions and conduct.

Refrain from any unsafe act that might endanger him/herself or fellow workers.

Use all safety devices and personal protective equipment provided for his/her protection.

Report all hazards, incidents, and near-miss occurrences to their immediate supervisor or Safety Director, regardless of whether or not injury or property damaged was involved.

Promptly report all injuries and suspected work related illnesses, however slight, to his/her immediate supervisor or Safety Director.

Participate in safety committee meetings, training sessions, and surveys as requested and provide input into how to improve safety.

Notify the Safety Director immediately of any change in physical or mental condition or use of prescription drugs that would affect the employees’ job performance or the safety of him/herself or others.

Notify the Human Resources Manager within five days of any serious driving, drug/alcohol, or criminal convictions.

Be a safe worker on (and off) the job. Help coworkers do their job safely. Come to work everyday with a safe attitude.

Accountability for Safety

Everyone is accountable for safety. Management, the Safety Director, and/or the Safety Committee will establish safety objectives and develop and direct accident prevention activities. All employees should strive to reach those objectives and will be evaluated accordingly. All managers’ and supervisors’ annual appraisals will include safety (results to objectives in their area and company wide) as well as an audit of their performance of their safety responsibilities. All employees’ salary reviews will be affected by the company’s safety performance record.

Appraisals, which include safety records, will also be performed on all employees seeking a promotion.

Opinion Survey

The Company requests ongoing comments and feedback from all employees. In addition, annually the company will request all employees’ opinions and input on the Company’s safety program through an opinion survey. Be honest. You know your job better than anyone else.

Therefore you can provide valuable input into performing the job safely. Changes to existing safety programs, rules, procedures, etc. may be influenced by your responses. Full cooperation of all employees is expected.

Employee Suggestions

Safety suggestions from employees are welcomed and encouraged. To make a safety suggestion, complete the following form and provide it to the Safety Director. The Safety Committee at their next meeting will review the suggestion. Responses to suggestions will be discussed with the individual or posted along with the Safety Committee Minutes

Employee’s Safety Suggestion

Employee’s Name (optional): Date:

Supervisor’s Name:

CURRENT PRACTICE OR CONDITION

SUGGESTION

BENEFITS EXPECTED FROM CHANGE

(FOR SAFETY COMMITTEE USE ONLY)

Year: Number:

Suggestion Implemented? Yes - as submitted Yes - with changes No

Implementation Date:

Comments/Changes Made/Reason for change or not implemented:

Standards

Safe Operating Procedures

All employees are responsible for safety. The following applies to all employees:

Rules

Comply with all established safety rules, regulations, procedures, and instructions that are applicable to your own actions and conduct.

Promptly report all accidents, hazards, incidents, and near-miss and all other occurrences to your immediate supervisor, regardless of whether or not injury or property damage was involved.

Do not visit, talk to, or distract another employee who is operating a machine, or who is engaged in a work activity where the possibility of injury exists.

Do not participate in horseplay, scuffling, pushing, fighting, throwing things, or practical jokes.

Use handrails on steps, elevated platforms, scaffolds, or other elevations.

Assist others and ask for assistance in lifting and carrying heavy or awkward objects.

Personal stereos with headphones, i.e. Walkman, are not permitted to be worn in the workplace

Alcohol and drug use and possession on Company property are prohibited.

Housekeeping

Practice good housekeeping by keeping the work area, aisles, walkways, stairways, roads, or other points of egress clean and clear of all hazards.

Store and/or return parts, materials, tools, and equipment so as not to create a tripping hazard.

Clean-up scrap, nails, and other excess materials. Place trash and scrap in proper waste containers.

Keep work area floors clean, dry, and free of oils, grease and liquids. Remove all spills immediately.

Remove or bend down nails or sharp protrusions. Store parts, materials, or equipment with protruding sharp ends or edges where personnel can not accidentally bump into th

Disciplinary Program

The management of FRONTIER TOWER SERVICES, INC. considers no phase of operation or administration as being of greater importance than accident prevention. It is the policy of this organization, therefore, to provide and maintain safe and healthful working conditions and to follow operating practices that will safeguard all employees and result in safe working conditions and efficient operation. Safety will take precedence over expediency and shortcuts. Every attempt will be made to reduce the possibility of injuries.

Employees’ safety is to be the first consideration in operation of the organization. Safe practices on the part of the employees must be part of all operations. Employees must understand their personal responsibility for preventing injuries on and off the job. Accident prevention and efficient operational procedures/activities go hand in hand.

Management has established minimum safety rules which must be understood
and and followed. Failure to comply with the safety rules or failure to take due care and caution to prevent accidents and injuries will not be tolerated.

· Management insists that all employees observe and obey every rule,
safety regulation and verbal command as is necessary to maintain a safe and healthful workplace.

· All employees will be required to attend safety meetings and safety training. Employees should acknowledge with signature on the safety meeting/ training form that they were in attendance.

· Every incident involving personal injury, motor vehicle or property damage should be reported immediately to your supervisor.

· Employees know to be consuming or under the influence of drugs or alcohol are subject to immediate dismissal. Random drug/alcohol tests may be required.

· Horseplay, scuffling and other unsafe acts that have an adverse influence of safety will not be tolerated.

· Do not operate machinery without authority to do so.

· All hand tools, ladders, vehicles, shop equipment, and fire fighting equipment 
will be inspected periodically and maintained in safe operational condition.

· No employee should knowingly be permitted to work while their ability or alertness is impaired by fatigue, illness, or other causes that unnecessarily expose other employees to injury.

Good housekeeping should be maintained in the workplace at all times.

· Report unsafe equipment, tools and work condition to your supervisor.

· Never operate any machine unless all guards and safety devices are in place 
and in proper operating condition.

· Employees will wear personal protective equipment as required by their work 
activity.

· Properly care for and be responsible for all personal protective equipment.

· Do not stand or sit on the sides of moving equipment.

· Use of the active fall protection when working from heights above 6’ is 
mandatory.

· Comply at all times with all known federal, state, and local safety laws as well as employer safety regulations and policies.

· Violation of any of these safety rules may be cause for immediate disciplinary action.

Disciplinary action may include, but is not limited to any of the following sanctions, as appropriate:

*Warning
*Written Reprimand *Probation
*Temporary Suspension *Termination

Management will meet with the employee to discuss any violation and will inform the employee of the procedure that was violated and be instructed on the correct action to be taken.

First violation of any of the above mentioned safety regulations will result in a verbal or written warning, a second violation will be probation or temporary suspension and third warning will result in termination.

Your full cooperation is required to ensure the success of the organization’s accident prevention plan. If a problem is encountered or assistance is needed concerning the safety policy or safety rules please contact your superviso

Job Hazard Analysis ProgramJob Safety Analysis

JSAs are a process of determining physical requirements, environmental conditions and safety factors relating to a specific job or task. JSAs are best used for stationary or repetitive production tasks or product movement, in which the job, equipment and work environment change very little.

JSAs provide

PPE determination process

Resource for supervisors to train new employees

Control of job steps

Identification and control of potential hazards

Benchmark for accident investigation

Review of employee performance

Responsibilities

Management:

· Ensure complete & effective JSAs are developed for all production tasks

· Ensure JSAs are reviewed with new hires and annually thereafter

· Utilize JSAs in accident investigations and retraining

· Ensure JSAs are modified if a new step or process is added

· Ensure JSA’s are developed for non-routine tasks that have a high degree of safety risk

Supervisors:

· Use JSAs and SOP’s to train all new employees

· Use JSAs and SOP’s when performing job performance evaluations

· Develop and submit JSAs for all tasks in their area of responsibility

· Review relevant JSAs periodically with all employees assigned to their project

The most important person in JSA process is the Supervisor, who is in constant contact with employees and should be familiar with the hazards in their Department. Supervisors are in a better position to recognize and correct unsafe acts and conditions as they occur.

Project Manager:

· Assist Management and Supervisors in developing JSAs and SOPs

· Maintain a master file of all JSAs and SOPs

· Ensure new JSAs or SOPs are developed for new equipment or processes

· Ensure SOPs are posted for tasks that occur at fixed locations (i.e.. Bench Grinders, Boiler Operations, etc.)

Documents

Forms and documents available for developing JSAs are:

· Job Safety Analysis Form

· Job Safety Analysis Task Steps

JSA Process

A Job Safety Analysis consist of:

· Job Physical Requirements

· Job Environmental Conditions

· Personal Protective Equipment required

· Sequence of Basic Job Steps

· Potential Accident or Hazards associated with each step

· Safe Job Practice for each step

Job Safety Analysis are completed through the followings steps:

· Development of JSAs

· Review and approval of JSAs

· Implementation of JSAs

· Review and updating JSAs

· Periodic Training using JSAs

Development of JSA

There are many ways to develop JSA/SOPs, however, observation and team approach has proven the most reliable. By watching the tasks, the observer can see first hand what is required, recognize the hazards and recommend alternatives. Below is the sequence used to develop a JSA/SOP:

· Select the most experienced employee to observe

· Explain the purpose of your observations

· Observe the task and define the steps used to complete the assignment

· Record the basic steps

· Review the steps with the observed Employee for clarity

Observe the task a second time and identify any hazard potentials and record the findings. Hazard types may include:

· Impact

· Contact with Chemicals

· Caught on or between

· Lacerations

· Burns

· Fall or Slip

· RF Exposure

· Over exertion

· Cumulative Trauma

· Vehicle collision

· Observe the task a third time to develop corrective measures to all hazard potentials

· Review your findings with the Employee for clarity

· Complete the JSA form

· Review and Approval of JSA

After the draft copy of the JSA has been completed, it should be reviewed by a team consisting of the Project Manager, Supervisor, Sub Contractor Employer representatives and affected Employees. The team should discuss all questions. A final version is then drafted.

Implementation of JSA

The Supervisor then reviews completed JSA with the entire department. New hires and transfers should have the JSA reviewed with them and made part of the Employee's job performance evaluation.

Updating JSA’s

All new hazards, operations, equipment and tools should be updated on the JSA and communicated to all Employees as soon as possible. JSAs will become outdated if not reviewed periodically.

Periodic Training and Retraining

Periodically and as needed, the Project Managers with all Employees should review the JSA. JSA should be reviewed with the Employee during an accident investigation to help identify possible causes or problem areas

Accident ManagementAccident & Near Miss Reporting Procedures

If you have a near-miss situation while working, notify your supervisor immediately. The situation will be investigated and corrective action implemented to prevent future injury. Employees and witnesses must fully cooperate in the investigation.

If you are injured on the job:

Contact your supervisor, or the nearest coworker (who should notify a supervisor) if you are unable to contact your supervisor due to the severity of your injury.

The designated employee who is trained in first-aid and/or CPR should be immediately notified to assist in the situation.

First aid kits, which are prominently displayed throughout the workplace, should be made available and medical supplies promptly refilled (by the Safety Director).

If needed, the supervisor or his designee should transport the injured worker to the company’s designated medical facility to receive appropriate medical attention. A post- accident drug and/or alcohol test will be conducted in accordance with the company’s Drug- Free Workplace Policy.

If rescue personnel are summoned, the supervisor should delegate an individual to wait for the rescue team and escort them to the injured employee.

All witnesses to the accident should be available to speak with the Safety Director and/or supervisor and cooperate in all accident investigations.

The Safety Director should immediately notify the insurance company of the accident and file a workers’ compensation claim.

Every accident or near-miss situation should be reported immediately. Injured employees and witnesses to the accident will assist the supervisor in completing an accident investigation.

Injured employees must comply with the medical treatment provided by the treating physician, cooperate with the insurance company and its designees, and abide by the company’s return-to- work policy.

Accident Investigation

When an accident occurs, it is an indication that something has gone wrong. Accidents don’t just happen, they are caused. The basic cause(s) of accidents are unsafe acts and/or conditions. The supervisor must investigate every accident to determine the cause and to initiate corrective action to assure that similar type accidents will not recur from the same causes.

Supervisors should complete the following accident investigation form and submit a copy to the Safety Director and Safety Committee for review. The Committee and/or Safety Director should evaluate the corrective action taken or suggested by the supervisor and instruct if additional changes should be made.

APPENDIX A: ACCIDENT/INCIDENT INVESTIGATION PHASES

An Accident/Incident investigation has 4 phases: (1) Identify and collect facts; (2) Determine the basic causes; (3) Determine the root causes; and (4) Recommend corrective action.

Phase 1: Identify and Collect Facts

The initial efforts of an Accident/Incident investigation should be directed towards identifying and collecting facts. Facts are obtained by:

· Observing the Accident/Incident scene including equipment, tools, machinery and/or vehicles. Photographs can be helpful in documenting the physical scene.

· Interviewing involved people including employees, managers, engineers, contractors, and/or suppliers. Take notes to remember what has been said.

· Reviewing records including administrative procedures, technical practices, training records, and equipment specifications.

The investigator should refrain from making any conclusions until all facts are collected.

Phase 2: Determine Basic Causes

Once all the facts have been collected, the basic causes of the Accident/Incident should be determined. These include the obvious unsafe conditions and unsafe acts that led directly to the incident. There is generally at least one basic unsafe condition and one basic unsafe act for each incident.

Basic unsafe conditions might include:

· Defective tools or equipment,

· Material failure

· Improper storage

· Housekeeping deficiencies

· Lack of guarding.

Basic unsafe acts might include:

· Failure to follow procedures,

· Working at an unsafe speed,

· Making safety devices inoperative,

· Using unsafe equipment,

· Failure to use personal protective equipment,

· Taking unsafe positions or postures, or horseplay

Phase 3: Determine Root Causes

Unfortunately, many Accident/Incident investigations stop once the basic causes have been identified and corrected. For example, someone slips and falls on some oil and the oil is cleaned up. While this may prevent the exact same Accident/Incident from happening again (i.e., another Employee will not fall on the same spot of oil), it does not prevent recurrence of similar incidents. To truly prevent recurrence, the root causes must be identified and corrected.

Root causes are the reasons the basic causes occurred. They are identified by asking the question WHY? For example, why was oil on the floor? If it was from a leaking forklift, why was the forklift leaking? Why wasn’t the forklift leak identified and repaired? Why wasn’t the oil on the floor observed before someone got hurt? If it was observed, why wasn’t it cleaned up immediately?

The investigator should continue to ask WHY for a particular line of questioning until it is not practical or useful to do so any further. Generally, root causes fall into the following categories:

· Purchase of inadequate equipment

· Inadequate maintenance

· Inadequate design

· Inadequate knowledge

· Inadequate motivation

· Inadequate procedures

· Inadequate hazard identification processes

Phase 4: Recommend Corrective Action

For every basic cause and root cause identified, corrective action must be recommended. Some corrective action can be taken immediately, (e.g., basic causes can generally be corrected immediately).

However, correction of root causes will be most effective in preventing recurrence. Sometimes this might require long‐term actions due to complexity, economics, state‐of‐the‐art or other practical concerns. For example, purchase of new equipment, improved maintenance procedures, conduct of training programs or implementation of inspection programs may require longer time frames. This should not deter the investigator from making these types of recommendation

Supervisor’s Accident Investigation Report

(Completed by Supervisor of Injured Employee)

Company

Address

Name of Injured Employee

Dept.

Position

How long in position?

Date of Accident

Time of Accident

Nature of Injury

Injury Resulted in: Injury

Fatality Property Damage (specify)

Medical Treatment

None First Aid

Drug Tested? Yes No

EMT or Paramedic Doctor or Clinic Hospital

Alcohol Tested? Yes No

Days Lost Time?

What was the injured employee doing at the time of the accident?

How did the accident occur (brief description)?

What environmental factors (unsafe conditions) contributed to the accident? (see next page for examples)

What behavioral factors (unsafe acts) contributed to the accident? (see next page for examples)

What corrective actions can be taken to prevent recurrence? (see next page for examples)

What corrective actions have been taken to prevent recurrence?

Names of Witnesses

Supervisor

Date

Reviewed by:

Date

Behavior Based Safety Program

Frontier Tower Service, Inc. Behavior Based Safety (BBS) Program is an education and observation process used to improve safety and reduce risk in the workplace. This process uses a proactive approach and is intended to communicate to employees the elements and the procedures of Behavior‐Based Safety that will assist in reducing at‐risk behaviors which in turn reduces injuries in our workplaces.

SCOPE:

Frontier Tower Service, Inc BBS applies to all staff. Employees are permitted to participate in BBS initiatives already in place at customer job sites if required by the customer. Employees are requested to participate in Behavior‐Based Safety process and follow the process guidelines.

REQUIREMENTS:

Safety awareness is the foundation of the Behavior Based Safety process. The key concepts teach employees to recognize when they may be in one of the following states:

 Rushing

 Frustration

 Fatigue

 Complacency (which can cause or contribute to these critical errors)

 Eyes not on task

 Mind not on task

 Line of fire

 Loss of balance/traction/grip (which in turn increase the risk of injury)

The observation process is designed to raise safety awareness and provide a feedback mechanism for management to make changes in design, process or procedure in order to reduce at‐risk behaviors. The key to this process is raising awareness of behavior through observation and feedback. The process has three key elements:

Observation and Feedback

The process starts with the observation of workers including fellow employees, other contractor employees and customer employees as they perform their tasks. Observers collect information about worker performance and provide feedback via the observation card. The emphasis is not on who was observed but rather what behavior was observed. Observations provide direct, measurable information on employee work practices identifying both safe and unsafe behaviors. During the observation the observer records their findings on the BBS Observation Form. Items to be observed include but are not limited to:

Personal protective equipment

Procedures/Methods

 People

 Work environment

 Equipment

After the observation is made, the observer will review the observation with the observed employee using the following guidelines:

 Start with positive comments.

 Reinforce safe behaviors observed first.

 Describe and discuss what was unsafe.

 Solicit from observed employee explanation of his/her unsafe behavior with open‐ended questions.

 Re‐emphasize no consequence to observed employee.

Documenting feedback allows workers to assess what should be repeated and what should change to reduce risks in the workplace.

Data Management:

Frontier Tower Service, Inc will gather information and track results so a comparison of employee safety behavior can be made over time.

Analysis and Action Planning

Action plans are developed by the Safety Administrator to address unsafe behaviors. Action planning will include:

 Evaluating unsafe behaviors

 Developing an action plan for unsafe behaviors based on comments and feedback from observations.

 Designating timeframes within the action plan.

 Ensuring management support.

Action Plan Follow Up:

All action plans shall be arranged by a set time period. Follow‐up is necessary to improve effectiveness of the BBS and to ensure the closure of all actions listed. The follow‐up process will include:

 Monthly frequency for review of actions by the Safety Administrator, management and employees.

 Assign accountability for closeout of action plans

Document archiving of action plans with completed action items.

RESPONSIBILITIES

Oversight

The Safety Administrator has these oversight responsibilities:

 Act as the primary observer, ensuring regular and frequent observations throughout the company.

 Coach other observers and develop action plans to ensure continuous improvement.

 Ensure that all employees are trained on the Behavior Based Safety elements.

 Maintain communication with workforce in a timely manner (feedback).

 After reviewing and giving feedback the BBS/JSA cards should be given to the Safety Administrator

Each employee plays a specific role in the Behavioral Based Safety process. These roles include observe, observer, supervisor, and Safety Administrator.

Person being observed

 Be willing to be observed.

 Be open and cooperative.

 Avoid being defensive.

 Participate in problem‐solving meetings.

 Be familiar with the Behavior Based Safety process.

Person performing the observation

 Learn the Behavior Based Safety process and the benefits of reducing at‐risk behaviors.

 Promote the Behavior Based Safety process.

 Make observing proactive.

 Be open to coaching.

 Be courteous and helpful.

 Assist workers by offering suggestions to safely perform a task or help them with a task if necessary.

 Communicate with the workers being observed.

 Give constructive feedback after observations.

 Stress the safe behaviors before the at‐risk behaviors.

 Offer and work towards solutions of problems found.

 Record a comment for every recorded “at‐risk” to include what and why. Make quality observations, concentrating on quality comments.

Supervisor

 Actively promoting and participating in the Behavior Based Safety process by reviewing BBS Observation Forms and giving feedback, completing corrective actions needed, etc.

 Ensure that all employees are aware of what is expected of them regarding the BBS process.

 Encourage employees to participate in observations so that incidents/injuries are reduced in the workplace.

 Provide necessary resources to keep process productive.

 Attend safety meetings and offer feedback on areas of improvement.

 Refraining from using data from the Behavior Based Safety process in a punitive manner.

 Assisting in problem solving and completing corrective actions in a timely manner.

 Understanding the behavior safety process and the benefits of reducing at‐risk behaviors.

Safety Administrator

 Support the goals and objectives of the Behavior Based Safety process.

 Encourage, promote, provide technical support and assist in acquiring the resources needed for the Behavior Based Safety process.

 Address the concerns and suggestions of field personnel.

 Collect all observation data cards.

TRAINING

Appropriate staff shall be trained for the BBS and the observation process. The training program shall:

 Include supervisors on a required basis and craft and support employees on a voluntary.

 General employee awareness as related to how decisions affect behavior and the impact those decisions have on working safely.

 Be conducted using classroom and field settings. Types of training shall include:

 Management training

 New employee training

 Refresher (annual) training for all participants

Training elements will include:

 Program objectives and incident statistics reviewed

 How to conduct the observation

 How to complete the observation form

 What do the behaviors mean

 Feedback training and role play (mentoring and coaching)

 Employees should be aware they may be requested to be observed at any time

 Documentation of training

CRITICAL BEHAVIOR INVENTORY DEFINITIONS

Body Use and Position

Ascending/Descending:

Examples:

Is the person using an accepted method of ascending or descending?

Is the person in control of their motion and footing when they are changing elevations?

Is the employee using handrails when using stairs to maintain a minimum of two-point contact and taking one step at a time?

· When climbing on or off equipment and machinery, use the designed foot and handholds.

· When using a ladder, face the ladder and maintain a minimum of three-point contact.

· When using a ladder, avoid carrying objects in hands, such as tools, gloves, etc.

· When using an extension ladder, tie it off.

· 100% tied off, minimum of three-point contact.

Eyes on Path

Examples:

Is the person looking in the direction of travel when walking, cycling or operating mobile equipment?

Is the employee moving at a safe pace appropriate for the conditions?

Is the employee looking for hazards in the path below, above and to the sides?

Is the person’s vision unobstructed when in motion?

· When walking, look out for holes in walkway and possible tripping and slipping hazards.

· When walking and carrying a large object, keep eyes on walkway.

· Before walking across road, look in both directions.

· When working, look above, below, and to each side to identify obstruction.

·

Eyes on Task/Work

Examples:

Does the person keep their eyes on the work being performed?

Does the person have an unobstructed view of the work?

Does the person ignore distractions while doing the task?

· When using a power saw or grinding wheel, keep eyes on task at hand.

· When using a hammer, keep eyes on object to be struck.

Body Mechanics

Examples:

Is the employee using proper techniques for lifting and lowering, turning and pivoting and pushing and pulling?

Lifting and Lowering

Is the load close to the body?

Is the employee bending at the knees?

Does the person use legs and keep the back straight?

Turning and Pivoting

Does the person keep upper torso aligned with legs when performing standing tasks?

Does the employee avoid any twisting of the spine while lifting/carrying by pivoting the feet?

Pushing and Pulling

Does the person maintain a balanced body position while pushing/pulling?

Are feet positioned square with shoulders and at shoulder width?

Does the person push instead of pull when possible?

Is the motion smooth and effort under control with a steady non-jerking motion?

· When lifting keep load close to body.

· When lifting bend at the knees.

· When lifting use legs and keep back straight

· When pushing or pulling forks on forklift, large wrench, etc., maintain balance body position and solid footing.

· When pushing or pulling, use smooth, non-jerky motion.

· push instead of pull when possible.

Line of Fire

Examples:

Is the person positioned in such a way so that if something falls, slips, sprays or moves suddenly, he or she will not be directly in its path?

Is the person positioned to avoid being in the path of sudden release of energy (electrical, hydraulic, pneumatic, heat, etc.)?

· When cutting with a knife or other sharp instrument, cut away from you.

· When opening drains, keep body parts away from draining fluids. When sampling, venting, or draining stand upwind.

· When opening flanges, break the side away from you first.

Pinch Point

Examples:

Is the employee positioned in a manner to avoid contact with any moving equipment or machinery?Does the employee avoid being caught between any moving and stationary objects?

Does the person keep all body parts clear of moving equipment surfaces that have the potential to intersect or converge?

· When closing doors, keep hands clear of door being closed.

· When operating valves with handles creating pinch points, use a valve wrench.

· When working on or using equipment with moving parts, keep body parts clear.

· When using hand tools, be aware of swing radius and possible pinch points.

Assistance

Examples:

Does employee get assistance or use lifting device when handling heavy or awkward object (crane, forklift, come-a- long, chain fall, etc.)

· When lifting large or awkward objects, get assistance from co-worker or use a mechanical device.

· When handling heavy objects, use carry-deck When placing pipe in pipe rack, carry-deck, or chain

Environment

Housekeeping

Examples:

Is the work area kept clear of debris and loose objects?

Does the employee remove or dispose of trash, clutter or debris in the work area?

Does the employee clean the work area upon completion of the task?

Does the person place equipment, tools, supplies and materials in their proper place so as not to create clutter or obstructions?

· Is the surface from which a task is being performed structurally sound, stable, level, and does it provide good

· When erecting or dismantling scaffold, place all pieces flat on ground or in racks, keep clear walkways.When completing a job, clean up work area, including spilled liquids.

· When you observe a tripping hazard like a hose in the walkway or a slip/trip hazard, remove or clean it up. Don’t wait for someone else to do it.

· Keep clear walkways and work areas on all jobsites.

Walking/Working Surfaces

Examples

Is the surface from which a task is being performed structurally sound, stable, level, and does it provide good traction?Does the person make unstable surface dry and solid before walking, standing or working on them? Does the employee use walk way provided of raccess to working area and avoid short cuts, uneven and slippery surfaces?

· When ice or snow conditions exist, clean and salt as soon as possible.

· Avoid icy areas and look for a clear path to walk.When working with scaffolds, make sure you have good footing and traction.

· When working on grating, check for signs of deterioration.

· On uneven ground make sure you have solid footing.

· When stepping over or around piping, make sure of your footing.

Storage & Labeling

Examples

Are items not in use placed in designated areas clear of traffic areas, stacked squarely, not leaning and the larger items on the bottom?Are tools, equipment and materials not in use stored in racks, cabinets or other designated apparatus?

· When in storage or while being transported, secure compressed gas cylinders.

· Flammable paints and solvents have M.S.D.S labels and are stored in lockers that are clearly marked “Flammable Material Only”.

· When pulling samples, affix proper label on the sample can.

· When storing gas cylinders, store only in approved racks and areas.

· When storing gas cylinder, store in upright position

Lighting

Examples:

Is the lighting in area sufficient to safely perform the task?

Is a portable light, including flash light, used while working in dark area?

· When working at night or in low visibility, use accessory lights such as a flashlight or light bars.

· When unit lighting is inadequate, write a safety work order to fix the problem

Tools/Equipment

Tool Selection/Use/Condition

Examples:

Has the right tool for the job been selected and is it being used for its intended purpose?Is it in good condition?

· When prying tight flanges, use a flange spreader.

· When prying, select and use the proper pry bar for the job.

· When opening or closing valves, use a valve wrench.

· When using wrenches, never use a cheater bar for additional leverage

Equipment Installation/Condition/Access

Examples:

Does the equipment installation create any work hazards?

Is the equipment free from obvious defects and in good working order?Is equipment in the original condition and free of non- approved modifications?

Is equipment installed in a manner that allows safe access

· When a damaged piece of equipment is discovered, remove it from use immediately.

· Prior to returning equipment to service, repair or replace all broken or worn parts.

Vehicle/Selection/Use/Condition

Examples:

Did the employee select the right vehicle for the job?Is the employee using the vehicle for the designated task?

Is the vehicle in good operating condition?

· While operating vehicle, employee wears seat belts.

· When operating vehicle, operator makes eye contact with pedestrians or other vehicle operators before proceeding.

· Before using any vehicle, do a safety inspection

Personal Protective Equipment

Head Protection

Examples:

Is the appropriate head protection being worn for the task being performed?

Is the head protection in good condition, being worn properly and appropriate for the risk?

Is the head protection free of alterations or defects

· When wearing a hard-hat, be sure of the proper size and fit.

· When wearing hard-hat, make sure the bill is facing forward.

· When using a hard-hat, the hat should be clean and fee of any noticeable damage

Eye Protection

Examples:

Is eye protection in good condition, being worn properly, fitted well, and appropriate for the risk?

Is eye protection free from scratches or other damage that could reduce vision?

· When working in dusty or dirty areas, or in windy conditions, wear goggles.

· Where applicable, wear ANSI approves safety glasses with side shields.

· When entering areas within orange painted lines, wear goggles.

· For any special risks like corrosives or steam, wear goggles.

Face Protection

Examples:

Is face protection in good condition, worn properly, fitted well, and appropriate for the risk?

Is face protection free from scratches or other damage that could reduce vision?

· When pulling product samples, wear face shield and proper eye protection.

· When unplugging drain lines, wear face shield and proper eye protection.

· When disconnecting chemical lines, wear face shield and proper eye protection.

· For any special risks like corrosives or steam, wear face protection

Hearing Protection

Examples:

Is the employee safer wearing hearing protection?

Is hearing protection being worn in high noise areas?

Is the employee wearing hearing protection when it is necessary to raise their voice in order to be heard?

Is the hearing protection in good condition and being worn as designed?

· When going in or out of units, wear hearing protection.

· When unsure of noise level, wear hearing protection.

· When working in areas with solid yellow lines, wear hearing protection

Hand Protection

Examples:

Is the employee wearing the proper hand protection for the task being performed?

Is the hand protection in good condition and appropriate for the risk?

· When leather gloves become saturated, replace and discard them.

· When gloves are to be used, inspect for damage prior to use.

Foot Protection

Examples:

Is the appropriate foot protection being worn for the task being performed?

Is the foot protection in good condition, being worn properly and appropriate for the risk?

· While walking on icy surfaces, wear non-slip over boots.

· While climbing ladders or stairs, remove mud and debris from shoes prior to climbing

Fall Protection

Examples:

Is the employee safer wearing fall protection equipment?

Is the fall protection equipment being worn properly, fitting

Snugly around thighs and shoulders?

Is the lanyard and fall arrest in good condition and properly secured?

· When working 6’ above ground level, i.e. pipe rack or ladders, use a safety harness.

· When working on a scaffold, install handrails.

Personal Monitor

Examples:

Does employee wear personal H2S monitor when in unit?

Is the monitor in good condition, calibrated/verified

properly, worn properly?

· When working in unit, does each employee or member of workgroup have personal H2S monitor?

· Is it worn properly, in the breathing zone?

· Is it calibrated?

· Is it working?

Procedure

Communication of Hazards

Examples:

Is the necessary information being passed between those to ensure the work is conducted safely?

Can the employees involved see and/or hear each other?

Do they communicate about the work being performed and the potential hazards?

· When working around welders, workers are to inform helpers of the hazards of this job before work begins,

· read and discuss MSDS sheets.

Barricade

Examples:

In doing the job, are the employees safer when barricades are used?

Is the barricade in use adequate for the task?

Is the type of barricade used; such as barrier tape, signs, guards or other forms of job isolation, visible and in open sight?

When removing insulation, tape off work area or barricade.When excavating, use barricade to alert others to danger.When leaving excavation open over night, use lighted barricade.

Pre-Post Job Inspection

Examples:

Does employee inspect equipment/area before beginning task?

Does employee inspect equipment/area after completing task?

Does he have extinguisher within grasp?Does he have radio or air horn?

BEHAVIOUR OBSERVATION SHEET

Date: ________________Observer(s): __________________________ Location: ______________________

Observation

N/A

S

U

Comments

PERSONAL PROTECTIVE EQUIPMENT

. (Hard hat, Goggles, Boots, Safety Glasses, Harness

Is necessary PPE being worn?

Is PPE adequate for the job?

Is PPE being worn properly?

Is PPE in good condition?

PROTECTIVE DEFENSES

(Barricade, Tape, Tags, Tie-off, Warning signs, etc.

Is isolation adequate?

Is warning adequate?

Are defenses secured?

.

POSITIONS/ACTIONS OF PEOPLE

(Use of what-if approach to foresee the unexpected

Striking against or being struck by

Caught in or between objects

Falling at the same level or to a different level

Contact with temperature extremes

Contact with electric current

Contact with chemicals

Overexertion while lifting, pushing, pulling or re

TOOLS (File, Grinder, Stringer, Wrench, etc.)

Are the tools right for the job?

Are the tools being used properly?

Are the tools in safe condition?

.

EQUIPMENT (Cranes, JLG, Bobcat, etc.)

Is the equipment right for the job?

Is the equipment being used correctly?

Is the equipment in safe condition?

.

HOUSEKEEPING

Is the housekeeping standard adequate?

Is the housekeeping standard understood?

Is the housekeeping standard followed?

.

PROCEDURES

(Planning, Permits, SOP, JSA, Red tags, Pipe spec Procedures)

Are the procedures adequate?

Are the procedures established & understood?

7.3 Are the procedures maintained & followed?

TOTAL

FTSI 15

Behavior Observation Audit Card

Location:

Date:

Auditor:

Hazard

Fall from elevation

Struck By hazard(s)

Trip

PPE - Eye Protection

PPE - Gloves

PPE - Fall protection

PPE - Hearing

PPE - Other

Struck Against Hazard(s)

Driving Habits

Permit Complete

Excavations

Equipment

Near Miss Program Active

Total:

Manual lifting ProgramPurpose

FRONTIER TOWER SERVICE INC is committed to providing a safe and healthy working environment for all employees. Musculoskeletal disorders (MSD) account for a majority of reported injuries and we must minimize the risk and incidence of MSDs. To achieve this goal, FRONTIER TOWER SERVICE INC requires each worksite to establish and maintain a MSD, Lifting and Handling Loads Program with the following elements:

Ongoing training of management, supervisors, and employees (including new hires) on MSD awareness hazards and control measures

Training of specialized staff (on MSD hazard assessment and control measures

Tracking of MSD statistics

MSD hazard identification and assessment (see MSD Hazard Identification form)

Control of MSD hazards through the application of engineering and/or administrative controls

Proactively integrating ergonomics principles into workplace design and work techniques

A realization that personal protective equipment may only be used as a substitute for engineering or administrative controls if it is used in circumstances in which those controls are not practicable.

Key ResponsibilitiesFRONTIER TOWER SERVICE INC Safety Administrator

Develops local Lifting and Handling Loads Programs for all worksites in accordance with this procedure and ensures all employees are aware of the requirements of the local Lifting and Handling Loads Program.

· Communicate, promote and support the MSD, Lifting and Handling Loads Program.

· Conduct MSD training sessions and/or provide MSD training materials.

· Maintain records of MSD training that they provide in a manner that supports accuracy and ease of access for monitoring purposes.

· Monitor corrective actions taken as identified on incident reports.

· Support supervisors and the worksite JHSC in the Lifting and Handling Loads Program process.

· Assist in the investigation of MSD incidents to address injury hazards.

· Bring to the attention of HOUSTON CONTROLS, INC management any MSD hazards identified during their investigations, audits or inspections.

· Ensure distribution and awareness of MSD Hazard Identification Forms.

· Provide input into purchasing specifications for new tools, equipment and furniture as needed to reduce MSD hazards.

· Provide input into the development of safe work procedures to reduce MSD hazards.

Worksite Manager

Responsible for the implementation and maintenance of the Lifting and Handling Loads Program for their facility and ensuring all assets are made available for compliance with the procedure. He or she will also:

· Ensure that all worksite departments implement and maintain the provisions of the Lifting and Handling Loads Program.

· Seek regular reports to ensure that their worksite is in compliance with the Lifting and Handling Loads Program.

· Manual lifting equipment such as dollies, hand trucks, lift-assist devices, jacks, carts, hoists must be provided for employees. Other engineering controls such as conveyors, lift tables, and work station design should be considered.

· Use of provided manual lifting equipment by employees must be enforced.

Employees

· Shall attend all MSD related training for the task they are performing.

· Practice MSD prevention strategies as per MSD training.

· Comply with safe work procedures.

· Correctly use the equipment provided by HOUSTON CONTROLS, INC, according to manufacturers’ recommendations.

· Report to the supervisor any unsafe acts, unsafe tasks, unsafe conditions or equipment problems that create MSD hazards.

· Report any MSD incidents to the supervisor and cooperate in the investigation process.

ProcedureWorksite Assessment

Before manual lifting is performed, a hazard assessment must be completed. The assessment must consider size, bulk, and weight of the object(s), if mechanical lifting equipment is required, if two-man lift is required, whether vision is obscured while carrying and the walking surface and path where the object is to be carried. The assessment shall also include:

· Use of the MSD Hazard Identification form contained within this procedure

· Physical Demands

· Neck Back Shoulder Wrist

· Hand

· Knee Ankle/

· Feet

· Force Required and Working Distance

· Do employees push, pull, lift, lower, or carry objects that are too heavy or require too much force; away from the center of the body or in a jerky or twisting manner?

· Work Postures

· Is the back is curved too much or in a stooped position?

· Is the back is twisted during movements?

· Is the neck bent or twisted?

· Are the arms away from the body?

· Are the wrists flexed, extended or pinched positions?

· Repetitive Use of Similar Muscles

· Do employees perform movements over and over in the same way

· Static Muscle Use and Duration

· Do employees hold any of the above work postures for > 20 sec.?

· Stand for long periods with their knees locked?

· Stand in one position without moving or stretching?

· Contact Stress

· Do employees put localized pressure on any part of their body?

· Work Space Layout and Conditions

· Are there working heights, reaches in workspace, equipment, tool design, storage conditions, etc., that cause or contribute to employees experiencing any of the physical demands risk factors?

· Also consider seating, floor surfaces, the characteristics of objects handled, including size and shape, load condition and weight distribution, and container as well as tool and equipment handles.

· Organization of Work

· Are there work processes, monotonous job tasks, work recovery cycles, task variability, work rate, machine paced tasks or peak activity demands that cause or contribute to rushing, frustration, fatigue or other visible signs of stress?

· Environmental Conditions

· Are employees exposed to poor lighting, vibration, cold or hot air/wind/water?

Work Controls

FRONTIER TOWER SERVICE INC. must ensure based on the assessment, implement control measures to eliminate, minimize or reduce, so far as is reasonably practicable, the risk of musculoskeletal injury to the worker.

Handling Heavy or Awkward Loads

FRONTIER TOWER SERVICE INC will take all practicable means to adapt the heavy or awkward loads to facilitate lifting, holding or transporting by workers or to otherwise minimize the manual handling required. Those include:

Where use of lifting equipment is impractical or not possible, two man lifts must be used.

All loads carried on handcarts shall be secured.

All awkward type loads shall be secured to prevent tippage.

Additional methods include:

· reducing the weight of the load by dividing it into two or more manageable loads

· increasing the weight of the load so that no worker can handle it and therefore mechanical assistance is required

· reducing the capacity of the container

· reducing the distance the load must be held away from the body by reducing the size of the packaging

· providing hand holds

· team lift the object with two or more workers

· improve the layout of the work process to minimize the need to move materials

· reorganize the work method(s) to eliminate or reduce repeated handling of the same object

· rotate workers to jobs with light or no manual handling

· use mobile storage racks to avoid unnecessary loading and unloading.

Incidents and Injuries

If an employee reports symptoms of a MSI FRONTIER TOWER SERVICE INC will:

· Musculoskeletal injuries caused by improper lifting must be investigated and documented. Incorporation of investigation findings into work procedures must be accomplished to prevent future injuries.

· Injuries must be recorded and reported as required by 29 CFR Part 1904.

Review & Updating Lifting and Handling Loads Program

· Supervision must periodically evaluate work areas and employees' work techniques to assess the potential for and prevention of injuries. New operations should be evaluated to engineer out hazards before work processes are implemented.

Training

FRONTIER TOWER SERVICE INC shall ensure that a worker who may be exposed to the possibility of musculoskeletal injury is trained in specific measures to eliminate or reduce that possibility. Our training shall include:

· General principles of ergonomics,

· Recognition of hazards and injuries,

· Procedures for reporting hazardous conditions, and

· Methods and procedures for early reporting of injuries.

Additionally, job specific training will be given on safe lifting and work practices, hazards, and controls.

MSD Hazard Identification Form

Job Title:

Location of Assessment:

Task Assignment:

Hazard Identification applies to the following locations:

Date:

Location:

Completed by (Name/Title):

In Consultation with:

Status: Draft |_|Final |_|

1. Awkward Postures

Mark if required

· List task(s) requiring this posture

· What is the possible cause of the posture?

List possible control measure(s) and state if control measures have been implemented

Hazard Resolved

Neck

Working with the neck bent forward or to the side more than 30° for more than 2 hours total per day.

|_|

|_|

|_|

|_|

Date:

_______

Neck

Working with the neck rotated more than 45° in either direction for more than 4 hours total per day or working with the neck bent back /up more than 10° for more than 2 hours total per day

|_|

|_|

Date:

_______

Neck

Working with the elbow(s) at or above the shoulder for more than 2 hours total per day

|_|

|_|

Date:

_______

Shoulder

Working while sitting or standing with the back bent forward, sideways, or twisted more than 30° for more than 2 hours total per day

|_|

|_|

|_|

|_|

|_|

Date:

_______

Back

Working while sitting or standing with the back bent back more than 10°, and with no support for the back, for more than 2 hours total per day

|_|

|_|

Date:

_______

Knees

Employee squats/ kneels for more than 2 hours total per day

|_|

|_|

Date:

_______

2. Static Whole Body Postures

Mark if required

· List task(s) requiring this posture

· What is the possible cause of the posture?

List possible control measure(s) and state if control measures have been implemented

Hazard Resolved

Prolonged Sitting

Employee sits for more than 6 hours total per day

|_|

|_|

Date:

_______

Prolonged Standing

Employee stands on hard surface more than 4 hours total per day (standing in one location without taking > 2 steps in any direction)

|_|

|_|

Date:

_______

3a. Lift/Lower Forces (manual labor)

Mark if required

· List task(s) requiring this posture

· What is the possible cause of the posture?

List possible control measure(s) and state if control measures have been implemented

Hazard Resolved

Back/

Shoulder

Lift/lower objects up to 2 times an hour

Object close to the body: 35 lb. or more

Object away from the body: 17 lb. or more

|_|

|_|

Date:

_______

Lift/lower objects 3 to 60 times an hour

Object close to the body: 30 lb. or more

Object away from the body: 15 lb. or more

|_|

|_|

Date:

_______

Lift/lower objects 61 to 240 times an hour

Object close to the body: 25 lb. or more

Object away from the body: 15 lb. or more

|_|

|_|

Date:

_______

Lift/lower objects >5 lb. more than 240 times an hour (more than 4 times a minute)

|_|

|_|

Date:

_______

3b. Lift/Lower Forces (office work)

Mark if required

· List task(s) requiring this posture

· What is the possible cause of the posture?

List possible control measure(s) and state if control measures have been implemented

Hazard Resolved

Back/

Shoulder

Lift/lower objects up to 2 times an hour

- Object close to the body: 30 lb. or more

- Object away from the body: 15 lb. or more

|_|

|_|

Date:

_______

Lift/lower objects 3 to 60 times an hour

- Object close to the body: 25 lb. or more

- Object away from the body: 15 lb. or more

|_|

|_|

Date:

_______

Lift/lower objects 61 to 240 times an hour

- Object close to the body: 25 lb. or more

- Object away from the body: 10 lb. or more

|_|

|_|

Date:

_______

Lift/lower objects >5 lb. more than 240 times an hour (more than 4 times a minute)

|_|

|_|

Date:

_______

4a. Push/Pull Forces (manual labor)

(Carts, trolleys, rolls, cables, etc.)

NOTE: Push/Pull force is the force required to move the object, not the weight of the object itself.

Mark if required

· List task(s) requiring this posture

· What is the possible cause of the posture?

List possible control measure(s) and state if control measures have been implemented

Hazard Resolved

Back/

Shoulder

Pushing/pulling up to 2 times an hour with initial push/pull force of more than 50 lb.

|_|

|_|

Date:

_______

Pushing/pulling 3 to 120 times an hour, with initial push/pull force of more than 25 lb.

|_|

|_|

Date:

_______

Pushing/pulling forces >5 lb. more than 120 times an hour (more than twice a minute)

|_|

|_|

Date:

_______

4b. Push/Pull Forces (office work)

(Carts, trolleys, rolls, cables, etc.)

NOTE: Push/Pull force is the force required to move the object, not the weight of the object itself.

Mark if required

· List task(s) requiring this posture

· What is the possible cause of the posture?

List possible control measure(s) and state if control measures have been implemented

Hazard Resolved

Back/

Shoulder

Pushing/pulling up to 2 times an hour with initial push/pull force of more than 50 lb.

|_|

|_|

Date:

_______

Pushing/pulling 3 to 120 times an hour, with initial push/pull force of more than 25 lb.

|_|

|_|

Date:

_______

Pushing/pulling forces >5 lb. more than 120 times an hour (more than twice a minute)

|_|

|_|

Date:

_______

5. Repetition

Mark if required

· List task(s) requiring this posture

· What is the possible cause of the posture?

List possible control measure(s) and state if control measures have been implemented

Hazard Resolved

Neck, shoulders, elbows, wrists or hands

employee repeats the same motion with the neck, shoulders, elbows, wrists, or hands every few seconds with little or no variation for more than 2 hours total per day excluding computer use.

Check body part(s) that apply:

|_| Neck |_|Shoulder(s)

|_| Elbow(s)

|_| Wrist(s) |_| Hand(s)

|_|

|_|

Date:

_______

Computer Use

Employee uses computer more than 3 hours total per day

|_|

|_|

Date:

_______

6. Hand/Arm Vibration

Mark if required

· List task(s) requiring this posture

· What is the possible cause of the posture?

List possible control measure(s) and state if control measures have been implemented

Hazard Resolved

Hands

Arms

Use high vibration tools (impact wrenches, chain saws, jack hammers, riveting hammers) for more than 30 minutes total per day

|_|

|_|

Date:

_______

Use moderate vibration hand tools (grinders, sanders, jig saws) that typically have moderate vibration levels more than 2 hours total per day

|_|

|_|

Date:

_______

7. Repeated Impacts

Mark if required

· List task(s) requiring this posture

· What is the possible cause of the posture?

List possible control measure(s) and state if control measures have been implemented

Hazard Resolved

Hands

Knees

Employee uses one of the following as a hammer more than 10 times per hour and for more than 2 hours total per day.

(Check the body part(s) that apply)

|_|Hand (heel/base of palm), or |_| Knee

|_|

|_|

Date:

_______

Complete this section only if potential hazards have been identified in the “Mark if required” column:

1. How many employees are exposed to the hazards identified above and how often?

# of employees Exposed

How often? (describe in hours per day or week, as appropriate)

Awkward postures

Static whole body postures

Lift/lower forces

Push/pull forces

Repetition

Hand/arm vibration

Repeated impacts

2. In the past two years, how many MSD incidents been reported among employees who are exposed to the identified hazards? State the number of incidents and their nature (e.g., Lost Time, Medical Aid, First Aid, Incident only)

Frontier Tower Service, Inc.,

Drug and Alcohol Policy

This policy applies to all employees of

Frontier Tower Service, Inc.

SOUTH PLAINS COMPLIANCE

1419 34th St.

Lubbock, TX 79411

(806) 747-0800

[Type text]

Table of Contents

SECTION 1Policy Statement

SECTION 2Prohibitions

SECTION 3Conducting Alcohol Tests

Conducting Drug Tests

Specimen Collection Protocol

SECTION 4Required Testing

Pre-employment Testing

Random Testing

Reasonable Suspicion Testing

Post Accident Testing

SECTION 5Consequences of Positive Testing

SECTION 6Employee Education

Referral, Evaluation and Treatment

Access to Records

Reference List for Employee Assistance Program

SECTION 7Definitions

SECTION 4South Plains Compliance Services Information

SECTION 9Quality Assurance

SECTION 10Forms

Section 1

Policy Statement

FRONTIER TOWER SERVICE, INC. has a vital interest in maintaining safe, healthful and efficient working conditions for all its employees. Substance abuse may pose serious safety and health rises. not only to the user, but Also to co-workers and the public. Jt is, therefore, the policy of FRONTIER TOWER SERVICE, INC. to prevent. substance use or abuse' from having an adverse effect on our employees. FRONTIER TOWER SERVICE, INC. believes that employees have a right to work in an alcohol and drug free environment and to work with employees free from the effects-of alcohol and drugs.

Specifically, it is the policy of FRONTIER TOWER SERVICE, INC. that the use, purchase, transfer, possession, or presence in one's system of any controlled substance (except medically prescribed drugs) by any employee while on the company premises, engaged in company business. While operating company equipment, or while under the authority of FRONTIER TOWER SERVICE, INC. is strictly prohibited

FRONTIER TOWER SERVICE, INC. recognizes that the reputation and safe operation of FRONTIER TOWER SERVICE, INC. is dependent upon the physical and psychological well being of its employees. Accordingly, FRONTIER TOWER SERVICE, INC. has adopted the following policy to insure a safe and drug free work environment. All employees are advised that remaining drug free and medical y qualified to work are conditions of continued employment with FRONTIER TOWER SERVICE, INC.

FRONTIER TOWER SERVICE, INC. reserves the right to amend this policy at an1time. Such amendments to this policy shall be made in writing and copies of such amendments shall be distributed to all employees.

Brent Huckabee is the Drug and Alcohol Program Monitor for FRONTIER TOWER SERVICE, INC., and is designated to administrate and answer questions pertaining to this policy.

Section 2

Prohibitions

Alcohol Prohibitions,

Alcohol misuse that could affect the performance of an employee is strictly prohibited. Specific alcohol prohibitions include:

1. Reporting for duty or remaining on duty with an alcohol concentration. of 0.04 or greater.

2. Used while performing any duties of FRONTIER TOWER SER CE, INC.

3. Use during the 4 hours before performing duties of FRONTIER TOWER SERVICE, INC.

4. Use during 8 hours following a reportable accident, or until a post accident alcohol test is taken

5. Possession of alcohol, unless it is manifested and transported as part of a shipment. This includes the possession of medicines containing alcohol (prescription or over-the counter), unless the packaging seal is unbroken. I

6. Refusal to take a required test.

Drug Prohibitions

Controlled substances that could affect the performance any employee are strictly prohibited. Specific drug prohibitions include:

I. Use of any drug, except by *doctor's prescription, and then only if the doctor has advised the employee that the drug will not adversely affect the employee [S ability to perform the duties of FRONTIER TOWER SERVICE, INC.

'Note: Any therapeutic drug use must be reported to the employee's supervisor.

2. Reporting for duty or remaining on duty after having tested positive for controlled substances. .

3. Refusal to take a required test.

4

Section 3

Conducting TestsConducting Alcohol Tests

FRONTIER TOWER SERVICE, INC. does not allow employees to consume alcohol or be under the influence of alcohol while performing the duties of the company.

A number equal to or greater than 10% of the number of employees will be tested each year. Alcohol testing will be conducted by SOUTH PLAINS COMPLIANCE or their affiliates.

All testing will be done while, immediately prior 10, or immediately after the employ e has performed duties of FRONTIER TOWER, SERVICE, INC.

All testing will be performed by a certified technician, using either

breath or saliva alcohol screening devices. All positive results will be confirmed with an Evidential Breath Testing Device (EBT).

Any person with a 0.02 to 0.039 result on the confirmation test will be removed from performing duties for 24 hours. All persons with a result of 0.04 or greater will be removed from duty and disciplinary action will be taken up to and/or including termination.

All employees who wok on Exon-Mobile properties will be required to have a non-regulated Alcohol breath or saliva test before performing duties for Exon- Mobile. I

Employees will be notified by FRONTIER TOWER SERVICE, INC. of all positive alcohol lest results.

Conducting Drug Tests

Urine drug testing for five specific classes of drugs will be required as a term of employment. These tests will be performed by a Department of Health and Human Services (DHHS) certified laboratory that follows strict guidelines.

The drugs that will be tested for are:

Drug of Abuse Screening Limit Confirmation Limit

Cocaine 300 NG/ML150NGIML

Amphetamines 1000 NG/ML500NG/ML

Opiates2000 NGIML2000NGIML

Cannabinoids (THC) 50 NGIML15NGIML

Phencyclidine (PCP) 25 NG/ML25 NG/ML

*-25 NGIML if immunoassay specific for free morphine

Urinalysis collection will be conducted by SOUTH PLAINS COMPLIANCE, or their affiliates. The collection

will strictly follow chain-of-custody guidelines to insure the security and integrity of each specimen provided. In addit